ISSUANCE OF MAINTENANCE CERTIFICATION AUTHORISATION BY MAINTENANCE ORGANISATIONS

 

Introduction

 

Aircraft maintenance licences are issued to persons who have met the requirements set forth in ICAO Annex 1, 14 CFR Part 65, Model CARs Part 2 and EASA Part 66. This licence contains privileges of which the holder must exercise to retain the licence. An aircraft maintenance licence does not automatically qualify an individual to sign a maintenance release under a maintenance organization authority. The authority for a person to sign a release within the maintenance organization's jurisdiction should be separately granted by the maintenance organization, in accordance with appropriate section of the Civil Aviation Regulations (CARs), following specific training in regards to maintenance organization procedures and other regulatory training.

After obtaining a licence, the holder must go through the qualifying procedures of the organisation he is working for, to obtain a maintenance certification authorization or aircraft certification authorization to enable him to perform and certify maintenance and inspection work or an aircraft for which the holder is rated and the maintenance organization is approved.

A maintenance organization as permitted by CARs may authorize a person, that is not the holder of an aircraft maintenance licence to sign a maintenance release, in respect of work performed on parts intended for installation on an aircraft, by means of a Maintenance Certification Authorisation sometimes referred to as Shop Certification Authorisation (SCA). Prior to the issuance of an SCA, the maintenance organization is required to ensure that the person understands his/her responsibilities in accordance with the applicable regulations, and has demonstrated levels of knowledge and experience that meet the applicable requirements of CARs and the approved manuals in respect of the work to be certified.

According to European Union Aviation Safety Agency (EASA), “Certification authorization” means the authorization issued to certifying staff by the organisation and which specifies the fact that they may sign certificates of release to service within the limitations stated in such authorization on behalf of the approved organisation. Maintenance Certification Authorization otherwise called Personnel Authorization Certificate in some climes is used to give authority to maintenance personnel to certify the task he has performed on an aircraft or component or to release the aircraft to service. Maintenance Certification Authorization is issued to certifying staff who have undergone the required qualifying procedures documented in the procedure’s manual of the maintenance organisation or air carrier.

Qualifying a Maintenance Personnel for Maintenance Certification Authorization

Most maintenance organisations have developed procedures for qualifying of their certifying staff and quality control inspectors and these procedures are required to be accepted or approved by the regulatory authority. The maintenance organisation should establish the minimum requirements regarding the qualifications, training and competence of personnel for the grant of a maintenance certification authorization to sign a maintenance release. The requirements to qualify maintenance personnel to be certifying staff or inspector include the minimum requirements of being certificated by the regulatory authority which includes age, knowledge, experience, training and skill. This means the person must be a holder of an aircraft maintenance licence or certificate with appropriate ratings issued by the regulatory authority except for maintenance of components in the shop.  CARs require certifying staff and inspectors to be certificated under applicable licensing regulations, be familiar with inspection methods, techniques, practices, aids, equipment, and tools used to determine the airworthiness of the article, be proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected, and show appropriate verifiable experience and/or training for the particular area of responsibility. After meeting the minimum qualification requirements in the regulations, the maintenance organisation usually have procedures to establish and maintain the qualification of its certifying staff. These include training in the company policy and procedures, human factors, hazardous materials, fuel tank safety, regulations, continuation, aircraft type and components specific and customer-specific. The training of certifying staff ate usually managed by an appointed Training Manager in very big maintenance organisation or the Base Maintenance Manager in small maintenance organisation.

In some climes, the CARs require the maintenance organisations to ensure that certifying staff can demonstrate recent experience on the aircraft or product type intended to be endorsed in the individual authorization. The recent maintenance experience is understood as meeting the requirement of 6 months of experience in 2 years period preceding the intended date of issuance of the individual authorization whereas other climes requires in addition, a minimum of five (5)years maintenance experience to be eligible. The five-year experience requirement mentioned does not necessarily represent the experience gained within a single maintenance organization, but can be the cumulative pertinent experience gained within a number of maintenance organizations.
Competency Assessment

The maintenance certification authorization system ensures only qualified certifying staff and inspectors perform maintenance on aircraft and components and issue maintenance or airworthiness release.

The aim of the competence assessment is to ensure compliance of the maintenance certification authorisation holder with the relevant regulatory requirements, with the criteria defined in maintenance organisation procedures and to ensure that each holder possesses the expected competence(s) associated to his/her job function (proposed scope of work, authorization category), before granting him/her an initial individual authorisation. 

The maintenance organisation is required to demonstrate through a competence assessment that the certifying staff meets the qualification criteria of described above, has the relevant knowledge, skills and ability to perform the maintenance tasks related to his/her job function including the relevant language knowledge and is able to determine when the aircraft or aeronautical product is ready to release to service and when it should not be released to service.

In the case of initial authorisation or extension of the scope of an already existing authorisation, the competence assessment must be specifically tailored to the aircraft type (s) intended to be covered by the certifying staff authorization, the competence assessment shall include evaluation of “On the Job Performance” and /or “testing of knowledge” by appropriately qualified personnel, and in addition, it is recommended that the competence assessment form contains an open text field where the person responsible for the assessment records the questions raised, comments or any other information useful to support the recommendation for the pass/fail result. A “box-ticking” exercise would be pointless.

After qualifying a certifying staff or inspector, maintaining the proficiency is also required through a series of continuation training and actual performance of the maintenance task. To maintain proficiency, the certifying staff or inspector must have performed actual maintenance task for six (6) months within any consecutive two (2) year period. Which means, he must have exercised the privileges of his licence and maintenance certification authorization by actually performing maintenance or inspection task on an aircraft type, aircraft group system or any privileges granted in the scope of authorization.  The maintenance organisation must assess at all times the competence, qualification and capability of the holder of the maintenance certification authorization to carry out the privileges of his/her authorization. To renew or to extend the scope of his/her already existing authorisation. This assessment shall also take into consideration attitude and behaviour.

Maintenance Certification Authorization

 

Maintenance certification authorization document is usually issued or revoked under the authority of the Quality Manager following a recommendation from the Head of Maintenance or Base/Line Maintenance Manager. Authorization documents must confirm the level of authorization given and authorization files for individuals must be retained by the Quality Department. The maintenance certification authorization contains the authorization number, the scope and limitations, the issue and expiry date, the name, aircraft maintenance licence number, the signature specimen and stamp of the holder maintenance organization among others. Usually, the validity of the authorisation should not be beyond the licence validity because an expired licence renders the maintenance certification authorisation invalid. Just like the aircraft maintenance licence, the maintenance certification authorization must be available for inspection by regulatory authority’s inspector. The scope of maintenance certification authorization includes approval for return to service, required inspections (RII), final inspection, receiving inspection, preliminary inspection, special activities (e.g NDT and welding), airframe and power plant, avionics, aircraft type-specific, aircraft system-specific, or air operator-specific maintenance organization among others.

The certification authorization must be in a style that makes its scope clear to the certifying staff and any authorised person who may require to examine the authorization. Where codes are used to define the scope, the organisation shall make a code translation readily available. Authorised person means an official of the regulatory authorities who has responsibility for the oversight of the aircraft or component being maintained.

Management, Supervisory and Inspection Personnel Rosters and Records

Certain regulations require maintenance organisation to maintain a roster of management and supervisory personnel that includes the names of the maintenance organisation officials who are responsible for its management and the names of its supervisors who oversee maintenance functions; a roster with the names of all inspection personnel; and a roster of personnel authorized to sign a maintenance release for approving a maintained or altered article for return to service. In some Part 145 climes, only the roster of certifying staff is required to be maintained

In compliance with the above, an individual file is to be maintained that includes the employment summary of each individual that appears in the roster to include present title and scope of employment; the scope of present employment; total years of experience and the type of maintenance work performed; past relevant employment, with names of employers and periods of employment; and type of maintenance licence held and the ratings on that certificate, if applicable.

The management, supervisory and inspection personnel rosters maintained by the maintenance organisation are most times located in the Quality Assurance Department and the rosters is revised within five (5) business days by the maintenance organisation if there is termination, reassignment, change of duties or scope of the assignment, or addition of any personnel. The rosters are required to be kept two (2) years or three (3) years after the personnel must have left the repair station depending on the regulatory regime and must be kept in a secure location not accessible to the holder. The truth is that management, supervisory and certifying, staff rosters have an effect on the scope of approval of a maintenance organisation and that is why the maintenance organisation is required to inform the regulatory authority if there are changes.

Conclusion

Notwithstanding the above, if a certifying staff of maintenance organisation who is a holder of an aircraft maintenance licence does not have a particular rating required to be endorsed on his/her licence, some regulatory authorities permit the maintenance organisation to issue the certifying staff a maintenance certification authorisation for maintenance covered by the rating once and only for a period of 6 months. This is permitted if the maintenance organisation is satisfied that the certifying staff has been trained and assessed in accordance with the maintenance organisation procedures and the manufacturer’s training facility was used for the training of the certifying staff for the rating and the regulatory authority must be informed within 7 days.       

The maintenance certification authorization system in a maintenance organisation ensures certifying staff do not exercise the privileges of their licence and maintenance certification authorisation if they do not meet the requirements of the regulations and the company procedures.

      For example, common sense recommends the certifying staff not to exercise the privileges of their maintenance certification authorisation if they know or suspect that their physical or mental condition renders them unfit to exercise such privileges (impact to the safe maintenance operations).

If a certifying staff do not meet the recent experience requirement anymore for an aircraft type or rating, the certifying staff loses his or her rights to exercise the privileges of certifying staff. Most times, the licence itself is valid 5 years from the last renewal but the certification privileges are affected by the “recency” of experience. The recent experience is performing maintenance tasks as defined in the regulation on the aircraft type or rating six (6) months within any consecutive two (2) year period.

To regain the experience back, the certifying staff may either continue to accumulate maintenance experience until he or she gains the missing time required, or meet the provisions for the issue of appropriate privileges, which means going to a type-training course again, including OJT as necessary. Neither a short period of job training session nor an aircraft type refresher training is acceptable.  Demonstration of experience should be made on the particular aircraft type or rating or similar aircraft.

Apart from issuing maintenance certification authorisation to certifying staff who holds or does not hold an aircraft maintenance licence, the maintenance organisation in some climes is permitted to issue maintenance certification authorisation to flight crew to certify: 1) limited line maintenance tasks when away from a supported location 2) repetitive pre-flight Airworthiness Directives if the Airworthiness Directive confirms this is acceptable and training is given.  For AOG (aircraft grounded) situations the maintenance organisation may issue a one-off maintenance certification authorization to a suitably qualified person based in that location provided this action if used is reported to the regulatory authority within 7 days of its issuance and is documented in the maintenance organisation procedures manual.